Data Protection Policy

Personal Data Protection Policy

I. Our Commitment Regarding Your Personal Data

1. SALZBURG REAL ESTATE INVESTMENT S.A., a limited liability company, established and operating in accordance with the laws of Romania, with its registered office in Bucharest, Str. Dogarilor no. 26-28-30, Building A, ground floor, commercial space no. 2, Sector 2, registered in the records of the Trade Register under no. J2014009316404, having Tax ID RO33463915, as well as any existing company or any company that will exist at any time in the URBAN SPACES group will process the personal data of users of the website www.urban-spaces.ro in accordance with its Personal Data Protection Policy (“Policy“) as well as with the General Personal Data Protection Policy of the group of which the company is part, namely URBAN SPACES (“URBAN SPACES Policy“), in accordance with the legislation in force.
2. This Policy is based on the provisions of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the “General Data Protection Regulation” or “GDPR”), which entered into force on 25 May 2018, as well as on applicable national legislation.
3. Modalitatea de prelucrare a datelor cu caracter personal a URBAN SPACES este unitară în cadrul companiilor din grupul URBAN SPACES, respectiv: RONDA 37 DEVELOPMENT S.R.L., Romanian legal entity, having its registered office at 26–28–30 Dogarilor Street, Building A, ground floor, Commercial Unit No. 2, District 2, Bucharest, Romania, registered with the Trade Registry Office attached to the Bucharest Tribunal under No. J2025013527001, having Tax Identification Number (CUI) RO51350159; GATE 55 S.R.L., a Romanian legal entity, having its registered office at 26–28–30 Dogarilor Street, Building A, ground floor, Commercial Unit No. 2, District 2, Bucharest, Romania, registered with the Trade Registry Office attached to the Bucharest Tribunal under No. J2026005182000, having Tax Identification Number (CUI) RO53489197; NEW HERITAGE MR53 S.R.L. a Romanian legal entity, having its registered office at 26–28–30 Dogarilor Street, Building A, ground floor, Commercial Unit No. 2, District 2, Bucharest, Romania, registered with the Trade Registry Office attached to the Bucharest Tribunal under No. J2022007991400, having Tax Identification Number (CUI) RO46029900; KORO LANDO REAL ESTATE S.R.L., a Romanian legal entity, having its registered office at 368A, Răscruci Village, Bonțida Commune, Cluj County, Romania, registered with the Trade Registry Office under No. J2017000788120, having Tax Identification Number (CUI) RO37154858; HEUBACH INVEST GMBH & CO KG GROBGMAIN BUCHAREST BRANCH, a Romanian branch established and operating in accordance with Romanian law, having its registered office at 26–28–30 Dogarilor Street, Building A, ground floor, Commercial Unit No. 2, District 2, Bucharest, Romania, registered with the Trade Registry under No. J2013005825404, having Tax Identification Number (CUI) RO31598665, and the database is jointly administered by the URBAN SPACES group.
4. The manner in which personal data is processed by URBAN SPACES is uniform across the companies within the URBAN SPACES Group, namely RONDA 37 DEVELOPMENT S.R.L., GATE 55 S.R.L., NEW HERITAGE MR53 S.R.L., KORO LANDO REAL ESTATE S.R.L., and HEUBACH INVEST GMBH & CO KG – Bucharest Branch, and the database is jointly administered by the URBAN SPACES Group.
   The GDPR defines personal data as “any information relating to an identified or identifiable natural person (the ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
5. SALZBURG REAL ESTATE INVESTMENT S.A. se angajează să implementeze cele mai înalte standarde de confidențialitate și transparență cu privire la datele cu caracter personal pe care le prelucrează în activitatea curentă. Protecția și transparența totală în ceea ce privește prelucrarea datelor dumneavoastră cu caracter personal în cadrul activității noastre sunt obiectivele noastre de maximă importanță.
6. Orice informații referitoare la prelucrarea datelor dumneavoastră cu caracter personal pot fi solicitate la adresa office@urban-spaces.ro aparținând Responsabilului cu protecția datelor desemnat în conformitate cu dispozițiile GDPR.

II. Agreement

1. Your use of our services is subject to this Policy and the Cookie Policy. By using our services, you agree to the terms of this Policy. The purpose of this Policy is to inform our clients about how personal data is collected, stored, and used.
2. If you do not agree with the Policy, please stop using our services.
3. The use of the website www.urban-spaces.ro does not necessarily imply the provision of personal data. However, if you decide to provide us with personal data, we want to explain how we process the data you provide.

III. Categories of Personal Data Collected

The personal data we process as a result of your use of the website www.urban-spaces.ro may include:

• contact information, such as your first and last name, email address, phone number;
• details about the type of home you desire or other project-related information
• your IP address, which is processed when you connect with our controller on the site;
• details of your visits to our website (in this regard, we recommend you read the Cookie Policy);
• other information you send us when submitting a request on the site or by email or phone.

IV. Methods of Collecting Your Personal Data

We collect your data resulting from an email or phone request

1. We collect personal data such as name, surname, email address, and phone number for the purpose of maintaining correspondence or communication with you. Thus, if you submit a request by email or phone, we will process your data to resolve it.
2. In this context, if the situation you present in your request requires it, we may transmit your contact data to financial and governmental institutions, transport companies, or postal services.
3. Except for the situation outlined above, the data you provide while browsing the website www.urban-spaces.ro will be used solely for our own interest and will not be transmitted to third parties unless your prior consent has been obtained.

We collect your data resulting from a request to be contacted by a consultant

1. We collect personal data such as name, surname, email address, phone number, and interest in contracting (the type of home you desire), which results from your request to be contacted by a consultant in this regard, by filling in the fields on the website.
2. In this regard, our consultants will contact you to provide more information and send you a personalized offer.
3. If you have expressly consented to your personal data being processed for marketing purposes by SALZBURG REAL ESTATE INVESTMENT S.A., specifically for sending newsletters, information about SALZBURG REAL ESTATE INVESTMENT S.A. products and services, or events and contests organized by us, SALZBURG REAL ESTATE INVESTMENT S.A will process your data for marketing purposes.

V. Purposes for Which We Process Your Personal Data

We may collect and process personal data for the following purposes:

• offering our products and services consisting of apartment-type homes or villas in residential complexes built by SALZBURG REAL ESTATE INVESTMENT S.A and the companies within the group;
• sending invitations for events organized by SALZBURG REAL ESTATE INVESTMENT S.A and the companies within the group;
• complying with our legal obligations (such as obligations to maintain accounting records and supporting documents);
• analyzing and improving our services and communications to you;
• protecting the security and managing access to our premises, IT and communication systems, online platforms, websites, and other systems, preventing and detecting security threats, fraud, or other criminal or malicious activities;
• for the purpose of identifying persons authorized to transact on behalf of our clients, beneficiaries, suppliers, and/or service providers;
• transmitting them to third parties, if you have expressly given your consent;
• marketing campaigns, customer surveys, market analyses, raffles, contests, or other promotional activities or events, if you have expressly given your consent;
• for any purpose related to and/or ancillary to any of the above or any other purpose for which your personal data has been provided to us.

VI. Direct marketing

1. We promote our services to you and to others. We use customer information to send invitations and communications promoting the products and services we provide. To the extent that you have given your consent in this regard, by checking the box in the contact form, we may use the personal data you provide to send communications regarding the products and services we offer.
2. In all cases, you will have the option to unsubscribe from receiving marketing communications by accessing the unsubscribe link that you will find in each such communication.
3. Please note that in the event of an unsubscribe request, there may be a period of up to 48/72 hours during which you may still receive marketing information or communications, due to considerations related to system modification operations. Unsubscribing from marketing emails does not prevent the continued sending of transactional emails through which we may inform you about the status of a transaction we may conclude.

VII. Sharing and Transfer of Your Personal Data

1. We may provide access to the personal data you provide to companies within the URBAN SPACES group, but we will maintain control over your personal data and will use appropriate protection measures, in accordance with applicable law, to ensure the integrity and security of your personal data. Regarding access by other companies within the group, access will always be limited to the personal data they may need to provide a service to you.
2. We may also disclose your personal data when you instruct us or give us permission to do so, or when required by applicable law, requests from judicial or official bodies, or for the purpose of investigating actual or suspected fraudulent or criminal activities.
3. We will not transfer personal data outside the EEA, unless one or more specified safeguards or exceptions apply to the transfer, namely an adequacy decision or binding corporate rules.
4. In the absence of an adequacy decision or binding corporate rules, the transfer of personal data to a third country or an international organization shall take place only under the following conditions:
5. the data subject has explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfers for the data subject due to the absence of an adequacy decision and appropriate safeguards;
6. the transfer is necessary for the performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures taken at the data subject’s request;
7. the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person;
8. the transfer is necessary for important reasons of public interest;
9. the transfer is necessary for the establishment, exercise, or defense of legal claims; and/or

VIII. Storage and Security of Personal Data

1. Ensuring the confidentiality of the personal data you transmit to us is an important concern for us. We have implemented technical and organizational measures to maintain the confidentiality and security of your personal data, in accordance with our internal procedures regarding the storage, disclosure, and access to personal data. Personal data may be stored on our technological data systems, those of our contractors, or in printed format.

IX. Your Rights

We wish to inform you that, under the new regulations regarding personal data protection provided by the General Data Protection Regulation (EU) 2016/679, if we process your personal data, you have the following rights:

• the right of access, provided for in Article 15 of the GDPR, on the basis of which you can request us, free of charge, to confirm whether or not we process personal data concerning you. You can also request a copy of the data we process about you. Requests must include relevant information to enable us to identify you in our database. We will process your request within a maximum of 30 days;
• the right to information – implies informing data subjects in a concise, transparent, and easily accessible manner about the data processed;
• the right to rectification, provided for in Article 16 of the GDPR, which you can exercise by submitting a request asking us to modify the information we already have about you. You can submit such a request when you notice that your data is incomplete or inaccurate;
• the right to restriction of processing, provided for in Article 18 of the GDPR, which you can exercise when you contest the accuracy of the data, consider the processing unlawful, or object to the erasure of the data. Following the exercise of this right, we may continue to store your data, with other processing operations being possible only with your consent, except in cases expressly provided for by law;
• the right to data portability, provided for in Article 20 of the GDPR, which you can exercise only in cases where processing is based on your consent or a contract and only if your data is processed by automated means. If you meet the conditions, you can send us a request to port your data to the controller you desire;
• the right to object to the processing of data for marketing purposes, provided for in Article 21 of the GDPR. You can exercise this right at any time, and we guarantee that your data will no longer be processed for this purpose. However, it is possible that a reasonable period (up to 72 hours) may be required for the registration and resolution of your request, during which you may still receive marketing communications from us;
• the right to erasure, provided for in Article 17 of the GDPR, on the basis of which we are obliged to erase the personal data we process about you. This right is not absolute, applying only in certain situations expressly provided for by law. When submitting an erasure request, please note that deleting this data can be a complex process.
• the right to address the National Supervisory Authority for Personal Data Processing, the public authority in Romania, with its headquarters at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania, website http://www.dataprotection.ro, whose objective is to defend the fundamental rights and freedoms of natural persons, especially the right to private, family, and private life, in connection with the processing of personal data and the free movement of such data (“ANSPDCP”), if you notice a violation of the GDPR.

To exercise these rights, please send us a written request to the email address office@urban-spaces.ro, with the subject line “Personal Information Request”.

If you are not satisfied with how we have handled your request, you can contact the National Supervisory Authority for Personal Data Processing.

X. Updates to Our Privacy Policy

We reserve the right to periodically update and modify this Data Protection Policy to reflect any changes in how we process your personal data or any changes in legal requirements. In the event of any such changes, we will display the modified version of the Policy on our website and/or make it available in another way.

XI. Contact

For additional information regarding the content of the data protection policy, please contact us at the email address office@urban-spaces.ro.